Distributor Privacy Policy

Last Updated: 12 October 2026

HL Protein Private Limited ("Sarthi", "we", "us") operates the Sarthi Distributor Partner mobile application, the distributor web panel and related services (together, the "Distributor App"). This Policy explains how we collect, use, share, retain and protect personal data of distributors and of the people whose data distributors manage through the Distributor App (retailers, salesmen and drivers). It is published under the Information Technology Act, 2000 and its rules and the Digital Personal Data Protection Act, 2023 ("DPDP Act"), as applicable.

1. Data We Collect

(a) Distributor account and business data: owner/authorised person's name, mobile number, email; business name, constitution and address; GSTIN, PAN, FSSAI or trade licences and other KYC documents; bank account details for settlements and subscription payments; warehouse and territory details; subscription plan and billing history.

(b) Retailer data (processed for orders placed with you): retailer name, shop name, mobile number, business and delivery address, GSTIN, verification status, order and purchase history, credit limits and outstanding balances.

(c) Salesman data (added by you): name, mobile number, assigned retailers/routes, visits and orders taken, location during working hours where enabled, and performance records.

(d) Driver/delivery data (added by you): name, mobile number, assigned deliveries, delivery status and proof, location during deliveries where enabled, and cash/cheque collection records.

(e) Product and transaction data: products, SKUs, prices, slab pricing, stock, discounts, schemes, orders, invoices, returns, refunds and payment records (cash, bank transfer, cheque, credit, UPI).

(f) Location data: with permission, device location for territory management, route planning and delivery tracking. Permissions can be managed in device settings.

(g) Technical data: device model, OS, app version, IP address, device identifiers, notification token, crash and diagnostic logs.

2. Purposes

• Registering, verifying (KYC) and managing distributor accounts and subscriptions;
• Listing products and showing them to retailers in your service area;
• Receiving, processing and delivering retailer orders; generating invoices;
• Managing salesmen, drivers, routes, stock, pricing, schemes and credit;
• Recording payment collections, returns, refunds and settlements;
• Handling retailer complaints, disputes and grievances;
• Showing your legal name, address, GSTIN and contact details to retailers, as required by the Consumer Protection (E-Commerce) Rules, 2020;
• Notifications, support, analytics, security, fraud prevention and improving the platform;
• Complying with tax, accounting and other legal obligations.

3. Roles and Responsibilities for Data

• For your own account data, Sarthi decides how it is processed (Sarthi is the Data Fiduciary).
• For data of your salesmen and drivers, and retailer data you add or use for your own business, you are responsible for having a lawful basis and giving them any required notice; Sarthi processes that data on your behalf to provide the Distributor App.
• You must use retailer, salesman and driver data only to run orders and deliveries through Sarthi, keep it confidential, and not sell, misuse or export it for unrelated purposes.

4. Sharing

We do not sell personal data. We share data only as needed with:

• Retailers – your business name, address, GSTIN, contact details, and delivery/driver details for their orders;
• Your salesmen and drivers – data needed for their assigned work, as configured by you;
• Service providers – cloud hosting, SMS/WhatsApp/notification, maps, analytics (e.g. Google Firebase) and payment providers, under confidentiality obligations;
• Government or law-enforcement authorities – where required by law, including tax authorities;
• A successor entity in a merger, acquisition or restructuring, subject to this Policy.

5. Retention

We keep data while your account is active. After closure, we delete or anonymise personal data within a reasonable period, except order, invoice, payment and subscription records, which we keep for at least 8 years under GST and accounting laws, and data needed for pending disputes, dues recovery or legal compliance. Salesman/driver location history is kept only as long as needed for operations and disputes.

6. Security

We use encrypted transmission (HTTPS/TLS), role-based access controls, OTP/password authentication and monitoring. You must keep your login credentials and staff logins secure and remove access for staff who leave. We will notify affected persons and authorities of a personal data breach as required by law.

7. Your Rights

You may access, correct or update your data, request erasure (subject to legal retention), withdraw consent for optional processing, nominate a person to exercise your rights, and raise a grievance. Requests from your salesmen, drivers or retailers about data you manage will be forwarded to you, and we will help you respond. Email sarthi.wholesale@gmail.com; we respond within 30 days.

8. Children

The Distributor App is only for businesses and persons aged 18 or older. You must not add anyone under 18 as a salesman or driver.

9. Changes

We may update this Policy. Material changes will be notified in the app or by SMS/email, and the "Last Updated" date will change.

10. Contact and Grievance Officer

Grievance Officer: Bhavin Thakkar, Email: sarthi.wholesale@gmail.com, Phone: +91 97262 42888 (Mon–Sat, 10 AM – 7 PM IST). Grievances are acknowledged within 24 hours and resolved within 15 days.

HL Protein Private Limited
E2 Highway Estate, Linking Road, Sarkhej, Ahmedabad, Gujarat – 382210
GSTIN: 24AAECH9411R1Z5 | Phone: +91 97262 42888 | Email: sarthi.wholesale@gmail.com | Website: sarthiwholesale.com
Grievance Officer: Bhavin Thakkar (sarthi.wholesale@gmail.com)